The practical answer
Evaluate permissions as a sequence of real actions on a specific employer and draft version. Define who prepares the transmittal, who reviews it and who releases it, then test both permitted actions and attempted actions that should be denied.
A permissions screen with several role names does not prove that a 1094-C approval process works. This guide provides an original role matrix and a two-person review demonstration. These are proposed organizational controls, not IRS-mandated software roles. Adapt them to your team while keeping reporting authority, product access and transmission responsibility clear.
Separate preparation, approval and release decisions
Describe the work before naming the roles. Preparation includes importing source data, reviewing entity settings and changing draft transmittal fields. Approval confirms that an identified version has completed the employer's review. Release makes that approved version available for the actual transmission process. Some products combine these actions; the evaluator should understand exactly what a button does.
For the reporting context, the 2025 instructions require one authoritative transmittal for each ALE Member. Make changing that selection a specific permission in the demonstration because it changes where the employer-level summary is reported. A general edit permission may cover it, but the team should observe that behavior.
An internal approval is not automatically the form's signature or authorization to act for the employer. Ask the vendor to explain the separate roles and records used in its actual filing process.
Start with a role-permission matrix you can test
| Role | Expected work | Restriction to demonstrate |
|---|---|---|
| Data preparer | Import and revise assigned employer drafts. | Cannot independently approve and release the same work. |
| Reporting reviewer | Inspect evidence and approve an identified version. | Cannot approve an employer outside the assigned scope. |
| Release operator | Release the approved version and retrieve its outcome. | Cannot silently substitute a changed, unapproved version. |
| Read-only reviewer | Inspect assigned records and permitted review evidence. | Cannot edit values or initiate release. |
| Access administrator | Assign or remove organizational access. | Administrative changes remain attributable and reviewable. |
This matrix is a starting point, not a claim that all products have these role names. Where one employee holds several roles, document which decisions still require another person and how the product supports that separation. Test export permissions independently if the organization wants some reviewers to inspect summaries without downloading employee-level data.
Test action scope and employer scope together
Create approved synthetic data for two employers in a nonproduction environment. Give the preparer access to only one employer, then perform an allowed edit through the normal interface. Next attempt the corresponding action on the other employer and record the actual result. Do the same for approval, export and release as relevant to the purchased workflow.
A hidden button alone does not establish that the underlying action is restricted. Ask the vendor to demonstrate the normal supported route for that action using the restricted account and show the resulting denial or enforced boundary. Keep this a product demonstration with authorized test accounts, not an attempt to probe an unapproved system.
Record scope changes too. If a user moves teams, demonstrate removal of the old employer access and assignment of the new scope. Reopen the relevant workflow using that account so the evaluator can see whether the new permissions take effect as expected.
Worked example: a monthly edit after approval
Fictional example: Ridge Assembly's preparer creates 1094-C draft v3 with a June full-time employee count of 87. A reporting reviewer examines the source reconciliation and approves v3. Before release, the preparer receives a reviewed source correction and changes that count to 88, creating v4.
The evaluation's expected control is that approval of v3 does not silently become approval of v4. Ask the release operator to continue through the normal demonstration path. The product might require a new approval automatically, or the employer might need a documented manual hold and second review. Record which process was actually shown.
The reviewer then compares v3 and v4, verifies the single changed count and approves v4. The release operator should be able to identify v4 as the version selected for the next step. Keep both approvals and their version references. An audit entry saying approved, without identifying what was approved, cannot explain this sequence.
Inspect overrides, absence coverage and access administration
Ask how the team covers an absent reviewer without sharing an account. Demonstrate the substitute's assigned scope and confirm that the resulting action records identify the actual person who performed it. If the workflow permits an override, ask who may use it, what reason is captured, and how someone else later discovers that the normal sequence was bypassed.
Test whether an access administrator can grant themselves release permission, and document the observed behavior. The purpose is to understand the control and its review process, not to presume that every product uses the same administrative model. An emergency path should be an explicit decision in the evaluation, not an undocumented surprise during filing season.
Keep automation identities separate in the demonstration notes. If an integration imports or releases work, ask how the product identifies that operation and connects it to the organization's approval procedure. Do not infer human approval merely from the presence of an automated event.
Retain evidence that follows the approved version
Request a demonstration export containing employer, reporting year, version, relevant changes, approver identity, approval time and release action. Then locate the transmission outcome separately. Publication 5165 explains that receipt and acknowledgment evidence have different roles; a local release event does not by itself establish AIR acceptance.
Hand the evidence to a colleague who missed the session and ask them to reconstruct the Ridge Assembly example. They should be able to determine that v3 was approved, v4 changed the June count, and the later approval applied to v4. Record any gap between what the screen showed and what the export preserves.
Use the software evaluation scorecard to capture the demonstrated result and dependencies. Keep a short implementation checklist for role setup and substitute coverage so the demonstrated controls are actually configured when the employer begins using the product.
Two-person review follows the transmittal version
Read the workflow as text
- Preparer creates v3. The employer-scoped draft and supporting count evidence are ready for review.
- Reviewer approves v3. The approval identifies the version that was examined.
- A material edit creates v4. The changed draft requires the organization's documented review procedure.
- Release uses approved v4. The operator links release evidence to the version actually approved.
Put this guide to work
1094-C role and approval demonstration checklist
Save the editable text worksheet and use it with your own records. Keep completed copies in your secure working files.
Download the worksheet TXTCommon questions
Does the IRS require the exact roles in this checklist?
No. These are proposed organizational controls for evaluating software. The employer must separately satisfy its applicable reporting and authorization requirements. Product role names and the division of preparation, approval and release work vary.
Can one person both prepare and release a transmittal?
Some organizations or products allow it. If your intended process requires a second reviewer, demonstrate how that review is completed and documented before release. Record any accepted exception instead of claiming separation that the team does not actually practice.
Is hiding the release button enough to prove a permission works?
It is one observation, but it does not show the complete supported workflow. Ask the vendor to use a restricted demonstration account and show what happens when that account attempts the relevant action through the normal product route.
Should every edit require a new approval?
Define which changes affect the reviewed filing version and demonstrate the product's actual behavior. A material form-data change should not silently inherit an approval for different values under the proposed process. Record how administrative notes or other non-filing changes are handled.
What should happen when the usual reviewer is unavailable?
Use the organization's documented substitute process with an individually identified account and appropriate employer scope. The evidence should show who actually performed the review. Test the arrangement before filing work depends on it.
Official sources and scope
Sources checked September 5, 2026. Use the edition for the tax year and filing method you are working with; later instructions may change thresholds, fields, or procedures.
- IRS 2025 Instructions for Forms 1094-C and 1095-C
Tax year 2025 authoritative transmittal context; proposed software permissions are original evaluation practices.
- IRS Publication 5165, revised December 2025
AIR receipt and acknowledgment distinction used when evaluating release evidence.